Exhibit 1.01
Wabash National Corporation
Conflict Minerals Report
For The Year Ended December 31, 2020
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2020 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants for which conflict minerals are necessary to the functionality or production of products manufactured by the registrant or contracted by the registrant to be manufactured. For the purposes of the Rule, “conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”). These requirements apply to registrants whatever the geographic origin of the 3TG and whether or not they fund armed conflict.
As described in detail below, following a reasonable country of origin inquiry conducted with our supply base into the source and chain of custody of 3TG in our products, we have reason to believe that a portion of the 3TG that is necessary to the functionality or production of products we have manufactured or contracted to be manufactured may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) and may not be from recycled or scrap sources. This CMR is available on our website at https://ir.wabashnational.com/financials/sec-filings/default.aspx. This CMR is not subject to an independent private sector audit in accordance with guidance issued by the SEC on April 29, 2014 and updated guidance issued by the SEC on April 7, 2017.
1. Company Overview
This CMR has been prepared by management of Wabash National Corporation (herein referred to as “Wabash,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries that are required to be consolidated. Wabash National Corporation (NYSE: WNC) is changing How the World Reaches YouTM. Wabash was founded in 1985 and incorporated as a corporation in Delaware in 1991, with its principal executive offices in Lafayette, Indiana, as a dry van trailer manufacturer. Today we are an innovation leader of engineered solutions for the transportation, logistics, and distribution industries. To that end, we design and manufacture a diverse range of products, including dry freight and refrigerated trailers, platform trailers, tank trailers, dry and refrigerated truck bodies, structural composite panels and products, trailer aerodynamic solutions, and specialty food grade and pharmaceutical equipment. The Company’s innovative products are sold under the following brand names: Wabash National®, Benson®, Brenner® Tank, Bulk Tank International, DuraPlate®, Extract Technology®, Supreme®, Transcraft®, Walker Engineered Products, and Walker Transport.
Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify entities upstream from our suppliers who provide us with products and/or raw materials necessary to the functionality or production of our products (“Direct Suppliers”). As such, we rely heavily on our Direct Suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower-tier suppliers. Current contracts with most of our key Direct Suppliers, which account for the majority of our sourced materials, are in effect for multiple year terms, and as a result, we cannot unilaterally impose new contract terms and flow-down requirements at this time. As we execute new contracts and/or renew contracts, we are requiring affected Direct Suppliers to provide us with geographic origin information concerning 3TG and smelters. Additionally, all new Direct Suppliers receive 3TG reporting requirements as a part of our new supplier information packet. It will take several years to ensure that all of our Direct Suppliers are contractually obligated to report this information to us as part of their normal business interactions with us. In the meantime, as described below, we have established a process to contact affected Direct Suppliers to collect necessary 3TG sourcing information. We have used and will continue to use the data collected through the process described below, and through our contractually obligated disclosures from our Direct Suppliers, to evaluate our supply chain to ensure compliance with the SEC’s current and future conflict minerals rules.
Reasonable Country of Origin Inquiry
Presently, our supply chain consists of over 12,000 suppliers, including many suppliers providing us with services and/or products that are not necessary to the functionality or production of our products and/or products that do not contain 3TG. As such, it was not practicable to conduct a survey of our entire supply base. Instead, we targeted our top 30 Direct Suppliers and certain additional Direct Suppliers that we have deemed "high risk," either because we have previously determined that they source materials and components containing 3TG from one or more of the Covered Countries or because they supply us with complex electronic components. This assessment was made based upon an evaluation of the composition of the products and/or raw materials supplied to us. The Company contacted these Direct Suppliers, requesting each to provide 3TG geographic origin data using the Conflict Minerals Reporting Template (“CMRT”) maintained by the Responsible Minerals Initiative (“RMI,” formerly known as the Conflict-Free Sourcing
Initiative). Surveys conducted with other manufacturing companies confirmed that our risk-based approach to developing our list of our surveyed Direct Suppliers, as described above, is consistent with how many peer companies are approaching the Rule.
At this time, having conducted this reasonable country of origin inquiry, we have reason to believe that it is possible that some 3TG necessary to the functionality or production of the products we manufactured or contracted to have manufactured may have originated in the Covered Countries and may not be from recycled or scrap sources. Accordingly, we conducted further due diligence on the source and chain of custody of the 3TG contained in our products.
2. Due Diligence Process
2.1 Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organization for Economic Cooperation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016), and the related supplements for each of the 3TG minerals (the “OECD Guidance”).
2.2 Establish Strong Company Management Systems
Conflict Minerals Policy
Wabash is committed to working with our global supply chain to ensure compliance with the SEC’s Rule. We have established a conflict minerals compliance program, as outlined above, that is designed to follow the OECD Guidance. Our enterprise is fully engaged in implementing that program.
For additional information about our commitment to responsible sourcing and other human rights, see our Conflict Minerals Policy Statement and Code of Business Conduct and Ethics, which are both publicly available on our website at https://www.wabashnational.com/we-are-wabash/suppliers.
Internal Team
Our Senior Vice President, General Counsel and Chief Human Resources Officer, Corporate Secretary and our Vice President, Global Supply Chain established a cross-functional team of subject matter experts from relevant functions of finance, legal, and supply chain to create our 3TG compliance program and due diligence efforts necessary to comply with the Rule. As part of this team, our Vice President, Global Supply Chain, and Global Supply Chain Strategist lead our ongoing due diligence efforts with our Direct Suppliers. Senior management and members of the Audit Committee of our Board of Directors (the “Audit Committee”) are briefed about the results of our due diligence efforts at least annually.
Control Systems
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in the transportation industry and other relevant sectors, as well as our own Direct Suppliers, to encourage the disclosure of the 3TG status of all upstream entities held in common by our various supply chains. Our due diligence process includes utilization of industry-wide initiatives to conduct due diligence on upstream entities in our supply chains, such as the CMRT and the RMI’s list of Responsible Minerals Assurance Process (“RMAP”) Conformant Smelters and Refiners (formerly the Conflict-Free Smelter Program).
Our controls include, but are not limited to, our Code of Business Conduct and Ethics, which outlines expected behaviors for all Wabash employees and suppliers. Going forward, as discussed above, our controls will also include contractual disclosure requirements in our Direct Supplier contracts.
Supplier Engagement
We have invested in tools and developed internal processes and procedures to query and track supplier activity. In addition, we have included 3TG reporting requirements in our new supplier packets and we will continue to request 3TG reporting data as required from all of our Direct Suppliers. We will also utilize key opportunities such as annual executive management reviews with our suppliers to reinforce and review compliance.
Grievance Mechanism
We have multiple mechanisms and processes for employees and suppliers to use to report violations of Wabash’s policies. These are described in our Code of Business Conduct and Ethics, which is publicly available on our website at www.wabashnational.com.
Maintain Records
We have adopted a policy to retain relevant documentation requested from and disclosed by our suppliers.
2.3 Identify and Assess Risk in the Supply Chain
As outlined previously, since we do not typically have a direct relationship with 3TG smelters and refiners, our due diligence efforts undertaken to comply with the Rule rely heavily on our Direct Suppliers providing us with information about the source of 3TG contained in the products and raw materials supplied to us. Our Direct Suppliers are similarly reliant upon information provided by their suppliers. Many of our largest suppliers are also SEC registrants and subject to the Rule. However, our ability to comply with the Rule is dependent upon receipt of complete and accurate information from our Direct Suppliers.
2.4 Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, Wabash has an approved risk management plan, through which our 3TG compliance program is implemented, managed and monitored. As part of the risk management efforts undertaken as part of our 3TG compliance program, our Vice President, Global Supply Chain, regularly reviews 3TG data provided by our Direct Suppliers. Direct Suppliers who provide incomplete or inconsistent 3TG data are contacted to update and confirm the data provided until Wabash can conclude with a reasonable degree of certainty that the provided data is likely accurate. Updates regarding our due diligence process and this risk assessment are provided regularly to senior management and the Audit Committee.
As described above, we also utilize and participate in several industry-wide initiatives to diligence the 3TG status of upstream entities in our supply chain. We will continue to pursue training and participate in seminars to increase our awareness and further enhance our compliance efforts. As part of our risk management plan, and to ensure our suppliers understand our ongoing expectations to provide accurate and complete 3TG data, we will continue to engage suppliers in various ways such as training sessions, executive management reviews and our annual supplier conference.
2.5 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Since we do not have a direct relationship with 3TG smelters and refiners, we do not perform or direct audits of these upstream entities within our supply chain. We will support audits by our supply base, as necessary, and have augmented our own Direct Supplier audit process with questions and procedures to address compliance by our Direct Suppliers with the Rule.
2.6 Report on Supply Chain Due Diligence
Wabash has filed a Form SD which includes this CMR, and we have made our Form SD and CMR available on our website, demonstrating our progress in implementing our Conflict Minerals Policy Statement.
3. Due Diligence Results
Request Information
As described above, we conducted a survey of certain Direct Suppliers using the CMRT, which was developed to facilitate disclosure and communication of information regarding smelters and refiners that are the source of the 3TG in a company’s supply chain. It includes questions regarding a supplier’s conflict-free policies, engagement with its own direct suppliers, and a listing of the smelters and refiners that the respondent (and its own suppliers) utilizes in its own supply chain. In addition, the CMRT contains questions about the origin of 3TG included in the respondent’s products, as well as the respondent’s own due diligence efforts. Written instructions and recorded training illustrating the use of the tool is available on RMI’s website. The CMRT is being used by many of our peer companies in their due diligence processes related to 3TG.
Survey Responses
We received responses from 47 Direct Suppliers of the 50 surveyed, which represents approximately 50% of Wabash’s direct material spend surveyed in 2020. We reviewed the responses provided against criteria developed to determine whether further engagement with our Direct Suppliers was necessary. These criteria included: (1) untimely or incomplete responses, (2) inconsistencies within the data reported in the CMRT or in other provided documentation, or (3) uncertainty in the accuracy of the data reported in light of the product supplied by the Direct Supplier. We conducted further engagement with Direct Suppliers who met one or more of these criteria until we received data sufficient to allow Wabash to conclude with a reasonable degree of certainty that the provided data is likely accurate.
Approximately 53% of our responding Direct Suppliers reported using no 3TG in products sold to Wabash; 2% provided insufficient detail, rendering their responses undeterminable; and 45% reported using 3TG from within the Covered Countries, in some cases from smelters or refiners not included on the RMI’s list of RMAP Conformant Smelters and Refiners. In all cases where 3TG was reported being used, our suppliers could not determine if 3TG was in the products they sold to Wabash. Of the thousands of lines of smelter data reported to us, we were able to determine 263 smelters and refiners that are potentially in our supply chain, based on the information available through the RMAP. Of these 263 smelters and refiners, 244 were included on the RMAP Conformant Smelters and Refiners list, 19 of which were active on the RMAP Active Smelters and Refiners list, indicating they have committed to undergo an RMAP assessment. As we do not typically have a direct relationship with 3TG smelters and refiners, and thus are unable to directly audit or request documentation from these facilities, Wabash supports the refinement and expansion of the RMAP lists of Active Smelters and Refiners and Conformant Smelters and Refiners.
Efforts to Determine Mine or Location of Origin
Through our utilization of RMI resources, the OECD Guidance, and requesting that our Direct Suppliers complete the CMRT, we have determined that seeking information about 3TG smelters and refiners through our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain. Our Direct Suppliers did not provide information on mines of origin for 3TG used in our products manufactured during 2020. Accordingly, we do not have sufficient information to conclusively determine the mines or the locations of origin of the 3TG in our products or whether the 3TG in our products is from recycled or scrap sources.
Smelters or Refiners
Based on the Direct Supplier responses we received:
▪53% of responding Direct Suppliers reported using no 3TG in their products and, therefore, utilize no smelters or refiners of concern.
▪2% of responding Direct Suppliers provided responses with insufficient detail, rendering their responses indeterminable.
▪The remaining 45% of responding Direct Suppliers reported using 3TG from within the Covered Countries, along with lists of smelters and refiners utilized in their respective supply chains, although in many cases the responding Direct Suppliers indicated that they had not identified all of the smelters and refiners used to supply the products within the scope of their responses.
▪When smelter and refiner lists included verified smelter or refiner identification numbers in a response, we were able to confirm the following about those smelters or refiners:
▪244 (93%) are on the RMAP Conformant Smelters and Refiners list.
▪19 (7%) are on the Active Conformant Smelters and Refiners list.
▪The majority of our responding Direct Suppliers who do utilize 3TG in some or all of the products they sell to their entire customer base: (1) could not represent to us that any smelter or refiner entities they listed as supplying them with 3TG had actually been included in the supply chain for the products, parts and/or raw materials they supplied to Wabash; and/or (2) reported that it was “not known” or “undetermined” if 3TG had been supplied to them by smelters or refiners included in the supply chain for the products, parts and/or raw materials those Direct Suppliers supplied to Wabash.
The statements above are based on the reasonable country of origin inquiry process and due diligence performed in good faith by Wabash. As noted previously, these statements are based solely on the information received from our Direct Suppliers through this process. For a listing of smelters or refiners and their location reported to Wabash by its Direct Suppliers and determined as included on either the RMAP’s list of Conformant Smelters and Refiners or the RMAP’s list of Active Smelters and Refiners, please see Table 1 at the end of this CMR.
4. Steps to Be Taken to Mitigate Risk
We intend to take the following steps to improve the due diligence we conduct, in an effort to further mitigate risk that the 3TG necessary to the functionality or production of the products we manufacture or contract to manufacture could benefit armed groups in the Covered Countries:
▪Inclusion of 3TG flow-down requirements in Wabash’s new or renewed Direct Supplier contracts.
▪Revisit annually the scope of Direct Suppliers requested to supply information as part of our due diligence process.
▪Engage with Direct Suppliers, as deemed necessary, directing them to training resources in an attempt to increase the due diligence response rate and improve the content of the Direct Supplier survey responses.
▪Work with the Organisation for Economic Co-operation and Development and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.
TABLE 1
The following facilities are included on either the RMAP list of Conformant Smelters and Refiners or the RMAP list of Active Smelters and Refiners and were reported by Wabash’s Direct Suppliers as being in Wabash’s supply chain.
| | | | | | | | | | | | | | |
| Smelter ID | Metal | Smelter Name | Smelter Country | Status |
| CID001555 | Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
| CID000128 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| CID000969 | Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| CID002129 | Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| CID001193 | Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| CID002516 | Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID001029 | Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant |
| CID002777 | Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant |
| CID001352 | Gold | PAMP S.A. | SWITZERLAND | Conformant |
| CID000015 | Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| CID001188 | Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| CID002606 | Gold | Marsam Metals | BRAZIL | Conformant |
| CID001204 | Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant |
| CID002560 | Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant |
| CID000019 | Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| CID001798 | Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| CID000801 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| CID003425 | Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
| CID001149 | Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG | Conformant |
| CID001078 | Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| CID000041 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| CID001220 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
| CID001161 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
| CID001259 | Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| CID001397 | Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| CID001585 | Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| CID001113 | Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| CID001153 | Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| CID001993 | Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002243 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| CID002003 | Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| CID000233 | Gold | Chimet S.p.A. | ITALY | Conformant |
| CID000855 | Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| CID001534 | Gold | Royal Canadian Mint | CANADA | Conformant |
| CID001326 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant |
| | | | | | | | | | | | | | |
| CID000694 | Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| CID002509 | Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| CID000711 | Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Active |
| CID000082 | Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| CID002850 | Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant |
| CID001756 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant |
| CID000362 | Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
| CID000929 | Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant |
| CID000113 | Gold | Aurubis AG | GERMANY | Conformant |
| CID002763 | Gold | 8853 S.p.A. | ITALY | Conformant |
| CID002290 | Gold | SAFINA A.S. | CZECHIA | Conformant |
| CID002100 | Gold | YAMAKIN CO., LTD. | JAPAN | Conformant |
| CID002761 | Gold | SAAMP | FRANCE | Conformant |
| CID000058 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| CID000401 | Gold | Dowa | JAPAN | Conformant |
| CID001119 | Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| CID000189 | Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant |
| CID000185 | Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| CID000425 | Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
| CID001955 | Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| CID002224 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| CID001386 | Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant |
| CID002580 | Gold | T.C.A S.p.A | ITALY | Conformant |
| CID002605 | Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| CID002314 | Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
| CID002918 | Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| CID001236 | Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| CID000264 | Gold | Chugai Mining | JAPAN | Conformant |
| CID000981 | Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| CID002615 | Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| CID001622 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| CID002779 | Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
| CID002765 | Gold | Italpreziosi | ITALY | Conformant |
| CID002459 | Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| CID001980 | Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| CID000814 | Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| CID001152 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| CID000920 | Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| CID000807 | Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| CID001157 | Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| CID000157 | Gold | Boliden AB | SWEDEN | Conformant |
| CID000359 | Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| CID000035 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
| CID000823 | Gold | Japan Mint | JAPAN | Conformant |
| | | | | | | | | | | | | | |
| CID001938 | Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| CID001325 | Gold | Ohura Precious Metal Industry Co., Ltd | JAPAN | Conformant |
| CID003195 | Gold | TSK Pretech | KOREA, REPUBLIC OF | Conformant |
| CID002511 | Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
| CID001875 | Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
| CID001147 | Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
| CID001736 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| CID000493 | Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant |
| CID000937 | Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| CID002778 | Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| CID002973 | Gold | Safimet S.p.A | ITALY | Conformant |
| CID001916 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
| CID001761 | Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID002919 | Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| CID002030 | Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| CID000689 | Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| CID000957 | Gold | Kazzinc | KAZAKHSTAN | Conformant |
| CID001498 | Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
| CID000090 | Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| CID001512 | Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| CID003461 | Gold | Augmont Enterprises Private Limited | INDIA | Active |
| CID002582 | Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| CID000924 | Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
| CID000077 | Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| CID002561 | Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
| CID003424 | Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
| CID003500 | Gold | Alexy Metals | UNITED STATES OF AMERICA | Active |
| CID002762 | Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| CID002863 | Gold | Bangalore Refinery | INDIA | Conformant |
| CID000176 | Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| CID000707 | Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| CID003575 | Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
| CID002562 | Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | Active |
| CID001969 | Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| CID001891 | Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| CID002557 | Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
| CID002549 | Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
| CID000211 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| CID000616 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
| CID001192 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| CID001277 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| CID002847 | Tantalum | Power Resources Ltd. | NORTH MACEDONIA | Conformant |
| CID002550 | Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| | | | | | | | | | | | | | |
| CID000917 | Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
| CID002544 | Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
| CID000460 | Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
| CID001076 | Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
| CID002492 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| CID002547 | Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
| CID002508 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| CID001508 | Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| CID001869 | Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| CID002558 | Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| CID000291 | Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant |
| CID000914 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| CID002505 | Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
| CID000456 | Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002506 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| CID002545 | Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
| CID001522 | Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| CID001175 | Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
| CID001769 | Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
| CID002548 | Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002539 | Tantalum | KEMET Blue Metals | MEXICO | Conformant |
| CID002512 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| CID002504 | Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| CID002707 | Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| CID001200 | Tantalum | NPM Silmet AS | ESTONIA | Conformant |
| CID002842 | Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| CID001163 | Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| CID000092 | Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| CID002706 | Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| CID003397 | Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| CID001142 | Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002180 | Tin | Yunnan Tin Company Limited | CHINA | Conformant |
| CID001458 | Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| CID001482 | Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
| CID001231 | Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
| CID002773 | Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
| CID003190 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| CID002500 | Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
| CID001191 | Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| CID001490 | Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
| CID001486 | Tin | PT Timah Nusantara | INDONESIA | Active |
| CID001337 | Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| CID001460 | Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
| CID002849 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
| | | | | | | | | | | | | | |
| CID003325 | Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| CID000309 | Tin | PT Aries Kencana Sejahtera | INDONESIA | Active |
| CID001758 | Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| CID001182 | Tin | Minsur | PERU | Conformant |
| CID001453 | Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| CID003381 | Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant |
| CID000468 | Tin | Fenix Metals | POLAND | Conformant |
| CID002468 | Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| CID003524 | Tin | CRM Synergies | SPAIN | Active |
| CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| CID001070 | Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| CID002570 | Tin | CV Ayi Jaya | INDONESIA | Active |
| CID001406 | Tin | PT Babel Surya Alam Lestari | INDONESIA | Conformant |
| CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| CID002455 | Tin | CV Venus Inti Perkasa | INDONESIA | Active |
| CID001399 | Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
| CID001898 | Tin | Thaisarco | THAILAND | Conformant |
| CID002756 | Tin | Super Ligas | BRAZIL | Active |
| CID000292 | Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| CID003379 | Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | Conformant |
| CID001477 | Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
| CID001468 | Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
| CID003205 | Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| CID002835 | Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| CID000448 | Tin | Estanho de Rondonia S.A. | BRAZIL | Active |
| CID000402 | Tin | Dowa | JAPAN | Conformant |
| CID001539 | Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| CID001173 | Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
| CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
| CID002503 | Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| CID001402 | Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
| CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| CID002834 | Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Conformant |
| CID002774 | Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
| CID000438 | Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| CID003486 | Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Active |
| CID001105 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| CID001305 | Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | Active |
| CID002816 | Tin | PT Sukses Inti Makmur | INDONESIA | Active |
| CID000228 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| CID002593 | Tin | PT Rajehan Ariq | INDONESIA | Conformant |
| CID001908 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
| CID001428 | Tin | PT Bukit Timah | INDONESIA | Active |
| | | | | | | | | | | | | | |
| CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Conformant |
| CID000760 | Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
| CID002870 | Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Active |
| CID003387 | Tin | Luna Smelter, Ltd. | RWANDA | Conformant |
| CID002848 | Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
| CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| CID003182 | Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Conformant |
| CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| CID001889 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant |
| CID002830 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
| CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| CID002543 | Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | Conformant |
| CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
| CID003388 | Tungsten | KGETS CO., LTD. | KOREA, REPUBLIC OF | Conformant |
| CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| CID002845 | Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant |
| CID002541 | Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| CID002827 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| CID003408 | Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | Active |
| CID002542 | Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| CID000568 | Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
| CID002641 | Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
| CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
| CID003427 | Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | Active |
| CID000825 | Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| CID000769 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| CID002833 | Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
| CID003401 | Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Conformant |
| CID002645 | Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
| CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| CID000966 | Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| CID000105 | Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| CID003416 | Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | Active |
| CID002589 | Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| | | | | | | | | | | | | | |
| CID002649 | Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
| CID002843 | Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| CID000004 | Tungsten | A.L.M.T Corp. | JAPAN | Conformant |
| CID002724 | Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
| CID003407 | Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID002579 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
